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Government Claims for Clean-Up Costs Related to Cold-War-Era Contracts Rebuffed

Client Alert | less than 1 min read | 10.10.12

On September 30, a federal court dismissed the government's claims for clean-up costs associated with groundwater contamination resulting from Cold-War-era Air Force contracts for certain rockets. Dismissal of the government's claims, which alleged perchlorate and trichloroethylene contamination, was based in part on "hold harmless" language in Air Force facilities contracts and continues the trend of recent decisions in cases involving the government's obligation to pay for environmental remediation costs stemming from work performed under government contracts.


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Client Alert | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....

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